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VOYLES v. COMMISSIONER

Docket No. 20076-89.

60 T.C.M. 1064 (1990)

T.C. Memo. 1990-550

Earl and Mary E. Voyles v. Commissioner.

United States Tax Court.

Filed October 23, 1990.

Attorney(s) appearing for the Case

Earl Voyles and Mary E. Voyles, pro se. Steven K. Dick, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined a deficiency in petitioners' 1985 Federal income tax in the amount of $38,037.90. Following a concession,1 the sole issue for decision is whether a $129,800 payment that petitioner Earl Voyles received from his employer in 1985 is excludable from gross income as a gift under section 102(a).2

Findings of Fact

...

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